IR 05000454/1985042

Forwards Insp Repts 50-454/85-42,50-454/85-43 & 50-454/85-56 on 850812-1031 & Notice of Violation & Proposed Imposition of Civil Penalty

ML20197J548
Person / Time
Site:	Byron
Issue date:	05/06/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
Shared Package
ML20197J553	List: IR 05000454/1985042 IR 05000454/1985056 ML20197J575
References
EA-86-048, EA-86-48, NUDOCS 8605200070
Download: ML20197J548 (4)

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MAY 6 1986 Docket No. 50-454 License No. NPF-37 EA 86-48 Commonwealth Edison Company ATTN: Mr. James J. O'Connor President Post Office Box 767

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Chicago, IL 60690 l

Gentlemen:

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SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF' CIVIL PENALTY (NRC INSPECTION REPORTS NO. 50-454/85042(DRP); 50-454/85043(DRP)

and 50-454/85056(DRP))

This refers to inspections conducted during the periods August 12 through October 18, 1985 and October 2-31, 1985 of activities authorized by NRC Operating License NPF-37 for the Byron Nuclear Power Station, Unit 1. As a result of these inspections, certain of your activities appeared to be in violation of NRC requirements. The violations were identified in the above referenced reports sent to you by letters dated November 14, 1985 and November 22, 1985,

- respectively. They were also the subject of an Enforcement Conference held in the Region III office on November 27, 1985, between Mr. Bide L. Thomas and other members of your staff, and myself and other members of the NRC staf Item I discussed in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties occurred on March 6, 7, April 20, 23, an'd May 30, 31, 1985 and on 3 different occasions on July 24, 198 It involved the use of procedures containing instructions for incorrect valve alignments to conduct technical specification (TS) surveillances on the residual heat removal system (RHR).

This rendered both trains of RHR, a subsystem of the emergency core cooling system (ECCS), inoperable in that neither train was capable of injecting into all four reactor coolant system (RCS) cold legs while the plant was in Mode The Byron Unit 1 Final Safety Analysis Report (FSAR), Chapter 6, for a Large Break Loss of Coolant Accident (LOCA) states that the ECCS fulfills its safety function by injecting into all 4 RCS cold leg These events are significant because with both RHR trains only able to inject into 2 cold legs, the plants'

ability to adequately respond to a large break LOCA was significantly degrade On June 5,1985, the NRC issued a Severity Level IV Notice of Violation because two safety injection pumps were isolated while the plant was in Mode 3 (Inspection Report No. 454/85002(DRP). Your corrective actions for that violation, as stated in your letter dated July 10, 1985, included reviewing and revising all operating procedures involving ECCS systems that could affect technical specification LCOs. Apparently, these corrective actions were inadequate because RHR procedures still contained incorrect valve alignment instruction CERTIFIED MAIL 0605200070 860506 RETURN RECEIPT REQUESTED PDR ADOCK 050004 4 O

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$ Commonwealth Edison Company 2 MAY 6 1986 Item II of the enclosed Notice involves several examples of your failure to understand technical specifications, system operability, and associated action statements. Specifically, Violation II. A involves your determination after completing a July 15, 1985 surveillance test that Train B of the solid state protection system was operable, even though the main steam line isolation and auxiliary feedwater functions had not been verified during the test. Violation II.B involves your application of the wrong action statement after engineered safety features actuation system (ESFAS) Train B was declared inoperabl It also addresses the fact that ESFAS Train B was left in the test position in excess of the two hours allowed by plant technical specification Violations II.C and II.D involve the fact that action statement requirements were not met after plant personnel discovered potentially explosive gas mixtures in the waste gas holdup tank on July 6 and 11, 1985. Violation II.E involves your failure to take TS required grab samples of the waste gas holdup tank while hydrogen and oxygen analysers were out of service. Violation II.F involves your failure to perform adequate post-maintenance inspections on the control room ventilation system which resulted in components not being able to maintain the required negative pressur We are concerned that it appears that the above violations occurred as a result of inadequate management and supervision with regard to technical specification requirements. We are further concerned that some of these events should not have occurred if corrective actions to previous licensee event reports or NRC-i.dentified violations had been effectiv '

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To emphasize the need for you to ensure that: (1) the accident response capability for safety related systems is not adversely affected when performing surveillance procedure requirements; (2) system operability is evaluated by management personnel more effectively; (3) action statements are properly implemented when applicable; and (4) corrective actions taken in response to violations of NRC requirements are effective, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of One Hundred Thousand Dollars (5100,000) for the Violations described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985) (Enforcement Policy), Item I described in the enclosed Notice has been categorized as a Severity Level III violation and Item II as a Severity Level III problem. The base value of a civil penalty for each Severity Level III violation or problem is Fifty Thousand Dollars (S50,000). The escalation and mitigation factors in the enforcement policy were considered. While I recognize that you identified the violations and took prompt and extensive corrective actions, mitigation of the civil penalties would not be appropriate because of your prior poor performance related to Item I and the multiple examples of violations in Item I You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional action you plan to prevent recurrence. After reviewing your response to this Notice, including your corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with regulatory requirement s L

. Commonwealth Edison Company 3 MAY 6 1986 In accordance with 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511

Sincerely, Cr::,'-:1 % 0by

.N : ] 0, ,'. ':r James G. Keppler Regional Administrator Enclosures: Notice of Violation and t Proposed Imposition of Civil Penalties Inspection Reports No. 50-454/85042(DRP);

No. 50-454/85043(DRP); and

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No. 50-454/85056(DRP)

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cc w/ enclosures:

D. L. Farrar, Director of Nuclear Licensing V. I. Schlosser, Project Manager Gunner Sorensen, Site Project Superintendent R. E. Querto, Plant Manager DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Byron Resident Inspector, RIII Braidwood Phyllis Dunton, Attorney General's Office, Environmental Control Division D. W. Cassel, Jr. , Es Diane Chavez, DAARE/ SAFE Steve Lewis, ELD L. 01shan, NRR LPM H. S. Taylor, Quality Assurance Division g6

RI RIII R I RIII Nore bis Std ton D vis K er G, 6l f Gl613b

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Commonwealth Edison Ccmpany

, MY 6 1986 Distribution PDR SECY CA JMTaylor, IE RVollmer, IE JAxelrad, IE TPoindexter, IE JGKeppler, RIII JLieberman, ELD HDenton, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV

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BHayes, 01 SConnelly, OIA JCrooks, AE0D IE:ES IE:EA DCS NRC Resident Inspector Project Manager, NRR State of Illinois

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